This Privacy Policy [the “
Privacy Policy”] is created and published in
accordance with Rule 3 (1) of the
Information Technology (Intermediaries Guidelines) Rules, 2011, which requires the publishing of Privacy
Policies and Terms of Use for website access or usage. This Privacy Policy regulates your use of the
website
http://excluto.com/ , as well as email
communications received
from admin@excluto.com
admin@excluto.com
[collectively, referred to as the “
Platform”].
VC Bridge Private Limited, a firm located at G-7 Madhuban Colony, Gandhi Nagar, Jaipur- 302015,
Rajasthan, India [“
Excluto”], owns and operates the Platform. Excluto
recognises the importance of
maintaining the privacy of the information provided by you and is committed to protect your privacy.
Kindly read the Privacy Policy carefully before availing the services offered by the Platform. If you
decide to use the Services offered by the Platform, the same shall be deemed as an acceptance of this
Privacy Policy by you without any demur.
This Privacy Policy explains how Excluto, via this Platform, collects, uses, shares and protects
Personal & Sensitive Personal Information (“defined herein”) about the Users or visitors of the Services
or the Platform. This Privacy Policy is created to demonstrate Excluto commitment towards protection of
your privacy and your Personal & Sensitive Personal Information. Your use and access to the Services are
subject to this Privacy Policy and our Terms of Use.
This Privacy Policy has been published in compliance of the laws stated in Clause 2.1 of this Privacy
Policy.
Please note that this Privacy Policy is applicable to all instances where we play the role of a Data
Controller (“defined herein”) of your Personal Data, when we collect and process personal data about you
for offering our products or services (whether or not such role is defined in applicable legislation).
By visiting and/or using the Platform and/or Services offered by Excluto, you agree to the terms and
conditions of this Privacy Policy and it shall be deemed that you have read in full and accepted the
same. You hereby consent to our collection, use and sharing of your information as described in this
Privacy Policy. In the event that you use the Services on behalf of someone else or an entity, you
represent that you are authorised by such individual or entity to accept this Privacy Policy on such
individual’s or entity’s behalf.
Our Privacy Policy is subject to change at any time without notice. To make sure that you are aware of
any
1 Definition
1.1 “Account(s)” refers to User
profile(s) (created after
undergoing the Registration Process) by which
User(s) are able to create and share information, personal messages, communications and other
content.
1.2 “Data Controller” as defined under
General Data Protection
Regulations means the natural or legal person, public authority, agency or other body which, alone or
jointly with others, determines the purposes and means of the processing of personal data.
1.3 “Cookies” are small files stored on
your device (computer or
mobile device) while browsing through the Platform or Application.
1.4 “Fee(s)” means the charges as
prescribed in the Platform and
as payable by the User through the payment gateways available on the Platform for availing the Services
available on the Platform.
1.5 “End-User(s)” refers to person or
his/her representative(s)
or affiliate(s), who has/ have an Account (after undergoing the Registration Process) with the Platform to
avail the Services provided therein.
1.6 “Personal Information” as defined
under the Information
Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules,
2011 [the “SPI Rules”] means any information that relates to a natural person, which, either directly or
indirectly, in combination with other information available or likely to be available to a body corporate,
is capable of identifying such person.
1.7 “Sensitive Personal Data or
Information” as defined under
Rule 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal
Data or Information) Rules, 2011 [the “SPI Rules”].
1.8
“Registration Process” means the process which a User undergoes while
registering himself/ herself/
themselves on the Platform thereby creating an Account in accordance with the process mentioned in Clause
[.] of the Terms of Use available at [.]
1.9
“Service(s)” means and includes providing general knowledge information
regarding investments, market
trends, financial alongside information of venture capital funds (“VC Funds”) additionally it provides
network platform to the investors (“LP”) and VC Funds.
1.10
“Usage Data” is data collected automatically either generated by the use of
Service or from Service
infrastructure itself (for example, the duration of a page visit).
1.10
“You”, “Your”, “User” or “Users” refers to any individual, organisation,
association or to his/her/ their
representatives or affiliates, who utilises or visits the Platform and includes “End-User(s)”.
2 OBJECTIVE OF THIS PRIVACY POLICY
This Privacy Policy is published in compliance with, inter alia:
(1) Section 43A of the Information Technology Act, 2000;
(2) Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive
Personal
Information) Rules, 2011 [the “
SPI Rules ”];
(3) Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011;
(4) Rule 3(1) (a) Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules,
2021;
and
(5) Relevant privacy protection practices adopted by MENA
This Privacy Policy mentions the type of information collected from the Users, including Sensitive Personal
Data or Information, the purpose, means and modes of usage of such information and how and to whom such
information may be disclosed.
3 PERSONAL INFORMATION AND/OR THE SENSITIVE PERSONAL DATA OR INFORMATION COLLECTED BY
EXCLUTO
For providing the services that are available on the Platform Excluto requires information from the User(s)
for providing the User(s) with the suitable Services. The information collected may include ‘Personal
Information’ and/or ‘Sensitive Personal Data or Information’ as mentioned under the SPI Rules. The User(s)
understands that the Personal Information and/or the Sensitive Personal Data or Information is being
voluntarily provided by you. You hereby consent to the collection of such information by Excluto.
Information collected by Excluto from you may inter alia include the following:
A. PERSONAL DATA/ INFORMATION
Generally, the User(s) can visit and browse the Platform without disclosing the personal information.
However, to fully use the Services provided by Excluto, via the Platform, the User(s) is/ are required to
undergo the Registration Process as provided in the Terms of Use available at [.].
The Registration Process mentions the information that is mandatorily required and the information that is
optional on behalf of the User(s). The User will have the option to not provide such information by choosing
not to use a particular Service or feature of the Platform. The Personal Information that will be required
by the Platform (if so chosen) are as follows:
(1)
Contact Information: Information, inter alia, including name, email
address, password of the User’s
Account etc.
(2)
Information required for providing the Service: The Platform may ask
for
information regarding phone
numbers and email that will be linked with the Platform, social media profiles, financial and investment
related information or any other detail (in accordance with the prevailing laws) which may be required to
avail the Services on the Platform.
(3)
Payment and billing Information: Financial information such as bank
accounts, credit and debit card
details or other payment instrument details, payment method, billing name, billing address may be collected.
In future the payment information can be obtained and processed by third party for online payment The
payment information provided by the User(s) will be shared with the payment gateway as chosen by the
User(s).
(4)
Any other information: The Platform may collect any other information
which
is freely available in
public domain or accessible or furnished under the Right to Information Act, 2005 or any other law for the
time being in force, as the case may be, without your consent. Such information shall not be regarded as
Personal Information or Sensitive Personal Information.
B. USAGE DATA
Excluto may also collect information that the User’s browser sends whenever you visit the Platform [the
“
Usage Data”].
This Usage Data may include information such as your computer’s IP address, browser type, browser version,
the pages of our Platform that you visit, the time and date of your visit, the time spent on those pages,
unique device identifiers and other diagnostic data.
When you access Service with a device, this Usage Data may include information such as the type of device
you use, your device unique ID, the IP address of your device, your device operating system, the type of
Internet browser you use, unique device identifiers and other diagnostic data.
C. LOCATION DATA
We may use and store information about your location if you provide us permission for the same [“
Location
Data”]. Excluto uses this data to provide features of our Service, to improve & customize our
Services, and
provide efficient Service to the User(s).
You have an option to enable or disable location services, while using our Platform and the Services
provided by Excluto, at any time by way of your device settings.
D. TRACKING COOKIES DATA
We use data collection devices such as ‘Cookies’ and similar tracking technologies to enhance User(s)
experience and to track the activity on our Platform. Cookies are files with a small amount of data which
may include an anonymous unique identifier.
Cookies are sent to your browser from the Platform and stored on your device to help Excluto to provide
information in the interest of the User(s). Cookies are small files that store information on your computer,
mobile or any other device through which the User(s) uses/ visits the Platform. These are used inter-alia to
remember your sign-in credentials, helps Excluto to understand the
Services that are essential to most of the User(s). You can decline the use of Cookies in your browser.
Since each browser is different therefore the User(s) has to check with the browser to learn how to manage
Cookies. However, if the User(s) opts to not accept Cookies, such User(s) may not be able to avail some
portions of the Services offered on the Platform.
4 PURPOSE OF COLLECTION/ USAGE
Excluto may use the Personal Information and/or the Sensitive Personal Data or Information provided by the
User(s), for the following purposes:
(1) for the purpose of providing you the Services;
(2) for the purpose of improving the quality of the Services;
(3) for the purpose of providing User(s) with the information, updates and news related to our Services;
(4) for the purpose of transactional communications;
(5) for the purpose of financial transactions;
(6) for the purpose of debugging customer support related issues;
(7) for the purpose of receiving feedbacks from the User(s);
(8) for the purpose of responding to summons, court orders or other legal obligations;
(9) for the purpose of conducting market research and generating statistical analysis;
(10) for the purpose as mentioned under the Information Technology Act, 2000 and the rules
thereunder.
Excluto or any person/organisation acting on behalf of Excluto shall not be responsible for the authenticity
and accuracy of the Personal Information and/or the Sensitive Personal Data or Information provided by the
User(s).
5 RETENTION OF DATA
Excluto retains the Personal Information and/or the Sensitive Personal Data or Information only for as long
as it is necessary for the purposes as mentioned herein the Privacy Policy and for the purpose it was
collected.
Excluto retains the Personal Information and/or the Sensitive Personal Data or Information for the duration
for which the Service is provided to the User(s).
6 OBLIGATIONS OF THE USER(S) FOR THE PERSONAL INFORMATION AND/OR THE SENSITIVE PERSONAL
DATA OR INFORMATION
You hereby consent to the collection and use of the Personal Information and/or the Sensitive Personal Data
or Information, provided by you to Excluto, for any of the purposes stated herein.
The User agrees and understands that all the information provided to Excluto by the User(s), including
Personal Information and/or the Sensitive Personal Data or Information, is voluntary.
For creating the Account, the User is required to provide Personal Information and/or the Sensitive Personal
Data or Information such as the Username, User ID, email address, password provided by the User and valid
financial account information.
The User(s) agrees and understands that Excluto is not liable for the authenticity of the Personal
Information and/or the Sensitive Personal Data or Information provided/ supplied by the User(s).
The User(s) are responsible for the accuracy and correctness of the information that you submit to
Excluto.
If the User(s) intends to deregister his/her/their Account or requests that their information no longer be
used, the User(s) can click on “Delete Account” option displayed on the Platform, or can contact Excluto by
sending an email addressed to admin@excluto.com, . Upon receiving such request, Excluto shall not keep such
information in its databases beyond the required time.
After the withdrawal of consent, or cancellation of Account, Excluto may discontinue or may not be able in a
position to provide the Services to such User(s).
7 DISCLOSURE OF PERSONAL INFORMATION AND/OR THE SENSITIVE PERSONAL DATA OR INFORMATION
The following is applicable to all the User(s):
Excluto confirms and agrees that it does not sell or share any Personal Information about the User(s) with
other people/ organisation except to provide the Services under the Terms of Use or this Privacy
Policy.
Excluto shall only disclose the Personal Information and/or the Sensitive Personal Data or Information only
to the extent as will be necessary to provide its Services as under:
(1) The Platform may require the User to pay a certain amount of Fee via a credit card, debit card for the
Services rendered by Excluto. The User(s) may opt for Excluto to collect and store such User’s credit card
number and/or other financial information such as bank account numbers, in a digitally encrypted format, for
ease of payment processes and future references.
(2) When a User visits the Platform, Excluto will automatically receive the IP address of the User’s
computer,
User’s operating system and type of web browser that is being used. This will help Excluto to analyse the
overall trends which will help the Platform in improving its Services.
(3) Excluto, via the Platform, uses temporary cookies for checking whether the user is logged in or not , in
order to make it easy for User(s) to not enter login credentials often. These cookies do not store any
Personal Information and/or the Sensitive personal data or information of the User(s).
(4) Excluto has no control over the third-party websites that may be displayed as search results or links
from
within the Services. These third-party websites may place their own cookies or other files on the Users’
computer, collect data or solicit personal information from the Users, for which Excluto shall not be
liable.
(5) Other parties if so required by any law at the time being in force and in compliance of Excluto legal
obligation.
(5) Excluto shall disclose the Personal Information and/or the Sensitive personal data or information to
Government agency if so mandated under the law in force at the relevant time.
The following information collected will not be shared with any third parties or disclosed to any person
other than as required by law; Sensitive Personal Data or Information of any person being the password,
financial information such as bank account or credit card or debit card or other payment instrument details,
or any other sensitive personal information not essential for the continued use of the Website.
We may share Personal Information with our other corporate and /or associate entities and affiliates to help
detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents;
correlate related or multiple accounts to prevent abuse of our services; and to facilitate joint or
co-branded services that you request where such services are provided by more than one associate entity.
Those entities and affiliates may not market to you as a result of such sharing unless you explicitly
opt-in.
We may disclose Personal Information if required to do so by law or in the good faith belief that such
disclosure is reasonably necessary to respond to summons, court orders, or other legal process. We may
disclose Personal Information to law enforcement offices, third party rights owners, or others in the good
faith and belief that such disclosure is reasonably necessary to: enforce our Terms of Use or Privacy
Policy; respond to claims that an advertisement, posting or other content violates the rights of a third
party; or protect the rights, property or personal safety of our users or the general public.
We give access of your Personal Information only to those personnel’s/officials who are authorised in this
behalf.
Excluto has implemented best market practices and security policies, rules and technical measures to protect
the Personal Data/ Information of the User(s) from unauthorised access, improper use, disclosure of data,
unauthorised modification and damage or accidental loss.
8 TRANSFER AND SECURITY OF PERSONAL INFORMATION AND/OR SENSITIVE PERSONAL DATA OR
INFORMATION
The Personal Information and/or the Sensitive Personal Data or Information of the User(s) is maintained by
Excluto in its secured/ encrypted database. Excluto may also keep the records of electronic communications
with the User(s) through the Platform for the limited purpose as stated herein the Privacy Policy and for
customer support, research and development, for administrative purpose.
The Personal Information and/or the Sensitive Personal Data or Information of the User(s) may be transferred
to and maintained on a secured/ encrypted database outside your State or country and the laws might differ
accordingly.
The User(s) agrees and understands that the Personal Information and/or the Sensitive Personal Data or
Information provided by the User(s) are shared with the employees of Excluto who are authorised in this
behalf and on need-to-know basis for the purpose of rendering Services to the User(s).
The User(s) understands that all the employees of Excluto, who have access to such Personal Information
and/or the Sensitive Personal Data or Information are obligated to keep the same confidential. Excluto is
committed towards maintaining the Personal Information and/or the Sensitive Personal Data or Information of
the User(s) secret and confidential.
We do not sell, trade or share your Information to any third party (except subsidiaries/affiliates of
Excluto for related offerings) unless, we have been expressly authorized by you either in writing or
electronically to do so.
If Excluto or its subsidiaries, if any, are involved in a merger, acquisition or asset sale the Personal
information and the Personal Information and/or the Sensitive Personal Data or Information of the User(s)
may be transferred in accordance with law and also in accordance the agreements executed for such merger(s)/
acquisition(s)/ asset sale(s).
The Platform takes all reasonable precautions to protect the Users’ data (whether online or offline) and
User(s) Personal Information and/or the Sensitive Personal Data or Information. The User(s) understands that
no one, except the End-User(s) will have access to End-Users’ passwords for its Account.
Excluto shall not be liable to indemnify the User(s) for any loss suffered by the latter due to unauthorized
use of your Account and the password thereof.
9 AMENDMENTS IN PRIVACY POLICY
Excluto may update the Privacy Policy from time to time. The Platform will notify the Users of any changes
by posting the new Privacy Policy on the website available at [.] Excluto retains the right to change,
modify or terminate the terms of this Privacy Policy, or any portion of this Privacy Policy, at any time by
publishing such changes on the Website. The amended Privacy Policy would be effective as on the date of
change, which Excluto would post on the Website and it shall be binding upon you from such date. If you do
not agree to any of the terms and conditions in the amended Policy, you may discontinue from using the
service available on the Platform immediately.
The Users are advised to review this Privacy Policy periodically for any changes. Use of information Excluto
collects, is subject to the Privacy Policy in effect at the time such information is used. Your continued
use of the Services following the posting of changes to this Privacy Policy will constitute your consent and
acceptance of those changes.
10 RESTRICTIONS ON USAGE
You are not permitted to host, display, upload, modify, publish, transmit, update, share or distribute any
information that:
(1) belongs to another person and over which you have no right upon;
is defamatory, obscene, pornographic, grossly harmful, harassing, blasphemous, defamatory, obscene,
paedophilic, libellous, invading another's privacy, including bodily privacy, insulting or harassing on the
basis of gender, hateful, libellous, racially or ethnically objectionable, disparaging, relating to or
encouraging money laundering or gambling, or otherwise unlawful in any way;
(2) harms minors in any way; infringes on the rights of minor;
(3)infringes on any patent, trademark, copyright, or other proprietary rights; violates any current law;
includes software viruses or any other computer code, files, or programmes designed to disrupt, damage, or
limit the functioning of any computer resource;
(4) is patently false and untrue, and is written or published in any form, with the intent to mislead or
harass
a person, entity or agency for financial gain or to cause any injury to any person.
Excluto reserves the right to delete any content and/or remove any non-compliant information from the
Platform that violates any of the foregoing criteria.
Excluto also reserves its right to terminate the access to any User(s) immediately in case of non-compliance
with the Terms of Use and Privacy Policy.
11 CONSENT TO THIS POLICY
The User voluntarily acknowledges that this Privacy Policy is a part of the Terms of Use of the Platform.
The User agrees that visiting the Platform or utilising the Services of the Platform the User signifies its
consent to this Privacy Policy. User’s visit to the Website and use of the Services is subject to this
Privacy Policy and the Terms of Use.
12 JURISDICTION
This Policy is governed by Indian law, which includes, but is not limited to, the following:
(1) The Indian Contract Act, 1872;
(2) The (Indian) Information Technology Act, 2000;
(3)The (Indian) Information Technology (Reasonable Security Practices and Procedures and
(4) Sensitive Personal Information) Rules, 2011;
(5) The (Indian) Information Technology (Intermediaries Guidelines) Rules, 2011;and
(6)The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
This Platform was created in Jaipur. The laws of the State of Rajasthan will apply to this Policy. You
consent to the jurisdiction and venue of the courts in Jaipur, India in connection with any action, suit,
process, or claim arising under or by reason of this Privacy Policy by using this Platform.
13 GRIEVANCE CELL
If any User has any question regarding this Privacy Policy, access or usage of computer resource, and/or to
register any complaint such User can approach the Grievance Officer appointed by Excluto. The User(s) may
reach out the Grievance Officer vide an email addressed to. admin@excluto.com,, the official email-id of the
Grievance Officer.
The Grievance Officer and Excluto shall make reasonable and prompt efforts to resolve the issue of the
User(s). The details of the Grievance Officer are mentioned herein below:
Name : Apoorv Sharma
Address: G-7 Madhuban Colony Gandhi Nagar-302015 Jaipur, Rajasthan, India
Email: admin@excluto.com
Availability: From 10:00AM to 6 PM Monday to Friday.
